INVOLIO PRIVACY NOTICE

Last Updated: August 20, 2025

This Privacy Notice describes how Involio, Inc. (“we”, “us”, “our”) collects, uses and discloses information about you when you use our website (https://invoapp.com/), applications, services, tools and features, or otherwise interact with us (collectively, the “Services”). For the purposes of this Privacy Notice, “you” and “your” means you as the user of the Services. 

Please read this Privacy Notice carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice. If you do not understand or agree to this Privacy Notice, please do not use or access the Services.

1. CHANGES TO THIS PRIVACY NOTICE

We may modify this Privacy Notice from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Notice, post the updated version on the Services and take any other additional steps required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not continue to use or access the Services.

2. COLLECTION AND USE OF INFORMATION

When you use or access the Services, we collect certain categories of information about you from a variety of sources. In addition to the specific uses discussed below, we may use this information to provide and improve our products and services and to maintain our business relationship, as a matter of our legitimate interests, such as by enhancing the safety and security of our Services, providing customer support, complying with applicable legal obligations, enforcing any applicable terms of service, and protecting our rights and the rights of our employees, users or other individuals. 

Information You Provide to Us

Some features of the Services may require you to directly provide certain information, including information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services includes:

• Basic contact details, such as name, phone numbers, and email addresses. We use this information to create and maintain your account and provide the Services, as required to perform our contract with you, and because it is in our legitimate interest to communicate with you (including to tell you about products or services that may be of interest to you, to the extent you have consented to receiving marketing communications from us).

• Account information, such as username/ account handle, account picture and authentication data for account access. We use this information to provide the Services and to maintain and secure your account with us, as required to perform our contract with you or (for account picture only) in our legitimate interests to provide you a more personalized service. If you choose to register an account, you are responsible for keeping your account credentials safe. We recommend you do not share your access details with anyone else. If you believe your account has been compromised, please contact us immediately.

• Blockchain Wallet Information, including your publicly available blockchain address, if you connect your blockchain wallet to the Services. We use this information to provide the Services, to screen your wallet for any illicit activity, and to enable you to invest and transact through the Services, as required to perform our contract with you and in our legitimate interests to protect account security and comply with law. 

• Transaction information, such as the type of asset you purchase or sell, the amount, and other information about transactions made through the Services. We use this information to provide you with the Services, including to support investments and transactions that you make, as required to perform our contract with you.

• User-content, such as text posts, direct messages, photos, videos and other content, posted by you or sent by you to other users on our Services, as required to perform our contract with you and in our legitimate interests to make the Services engaging for you. This content may include information about trades that you have made and your financial portfolio(s) that you maintain on other platforms. As part of the Services, we or others, including other users of our Services, may store, display, reproduce, publish, or otherwise use such content alongside other account information (such as your username), and may or may not attribute it to you. If you choose to submit content to any public area of the Services, your content, username and other information associated with your account (including your profile photo, who you follow, and your interactions with other users’ posts) will be considered “public” and will be accessible by anyone, including us.

• Any other information you choose to include in communications with us, for example, when sending a message through the Services, in our legitimate interests to be responsive to your requests.

Information Collected Automatically

We and third parties also use cookies, pixels or other tracking technologies to automatically collect certain information about your interactions with the Services. This information is collected and used either with your consent where required under applicable law (for example, to personalize the Services for you, and to target, deliver and measure interest-based advertising) or because it is in our legitimate interests to tailor your experience with the Services, provide you with offers or promotions, run analytics, and better understand user interactions with the Services. 

We also collect information including:

• Device Data, such as your mobile device ID, model, and manufacturer, operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our mobile application, we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, information about your device’s camera or microphone, and information about the features of our application you accessed in our legitimate interests to effectively and efficiently provide the Services.

• Log and Usage Data, such as service-related diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings). We process this information in our legitimate interests to effectively and efficiently provide the Services.

• Location-based Data, such as approximate location, if you choose to provide it. 

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of cookies. If you so choose, you may block or delete certain of our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly. You may also opt-out of the collection and use of information for interest-based advertising by advertisers that are part of certain industry alliances, including through tools offered by the National Advertising Initiative, the Digital Advertising Alliance or the European Interactive Digital Advertising Alliance, by clicking the links provided. 

Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. 

Information Collected From Other Sources

We may obtain information about you from outside sources, including information that we collect directly from third parties and information from third parties that you choose to share with us. Such information includes:

• Information we receive when you choose to link any social media platforms to your account, such as Facebook or X, which we use to maintain your account and login information and provide the Services, in our legitimate interests to respond to your linking request and engage our users.

• Information you publicly post on our social channels or social media accounts, such as Discord, Telegram, or X, which we use in our legitimate interests to engage in community discussions and improve our Services. 

• Publicly available or visible information on blockchains or other public sources, including information regarding transfers of digital assets, which may then be associated with other information we have collected about you; we use this in our legitimate interests to give the best user experiance. 

Any information we receive from outside sources will be treated in accordance with this Privacy Notice. We are not responsible for thde accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Third-Party Websites and Links.

3. DISCLOSURE OF YOUR INFORMATION

We may disclose your information for legitimate purposes as set out in this Privacy Notice, including the following categories of third parties: 

• Third party users of the Services, based on your interactions with and use of the Services, including when you post content (including photos, GIFs, videos and other content of posts that you share), create portfolios, and add trades to your portfolio as a matter of our legitimate interests to efficiently provide the Services. This information, alongside information that may identify you such as your account handle and account picture, is publicly available on the Services. You may also disclose information when you choose to directly interact with other users through our Services, such as by following other users, liking or commenting on their content, or sending them a private message through the Services. We or others may store, display, reproduce, publish, or otherwise use or disclose such information, and may or may not attribute it to you.

• Our affiliates or others within our corporate group as a matter of our legitimate interests to efficiently provide the Services.

• Vendors or other service providers who help us provide the Services, including for system administration, cloud storage, security, customer relationship management, marketing communications, and web analytics purposes. We also Orderly to provide financial services support for the Services, and enable you to place trades directly through the Services as a matter of our legitimate interests to efficiently provide the Services.

• Third parties to whom you request or direct us to disclose information, such as through your use of login integrations or your use of the Services to conduct activities on public blockchains.

• Professional advisors, such as auditors, law firms, or accounting firms, as a matter of our legitimate interests to assess, protect, enforce and defend our rights and to comply with our legal and regulatory obligations.

• Third parties in connection with or anticipation of an asset sale, merger, bankruptcy, or other business transaction, as a matter of our legitimate interests to run a successful and efficient business.

We may also disclose your information as needed to comply with applicable law or any obligations thereunder or in our legitimate interests to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of service, and to ensure the safety and security of our business, employees, and users.

4. SOCIAL FEATURES 

Certain features of the Services allow you to initiate interactions between the Services and third-party services or platforms, such as social networks (“Social Features”). Social Features may include features that allow you to access our pages on third-party platforms, and from there to “like” or “share” our content. Use of Social Features may allow a third party to collect and/or use your information. If you use Social Features, information you post or make accessible may be publicly displayed by the third-party service. Both we and the third party may have access to information about you and your use of both the Services and the third-party service. For more information, see the section below, Third-Party Websites and Links.

5. THIRD-PARTY WEBSITES AND LINKS

We may provide links to third-party websites or platforms. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Information you provide on public or semi-public venues, such as third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators. 

6. CHILDREN’S PRIVACY

Our Services are not intended for children, and we do not seek or knowingly collect any personal information about children. If we become aware that we have unknowingly collected information about a child, in particular any child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

7. DATA SECURITY AND RETENTION

Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information. 

We retain your information for as long as is reasonably necessary for the purposes specified in this Privacy Notice. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide you the Services, resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security and integrity, or protect ourselves, including our rights, property or products.

8. DATA TRANSFERS

The information we collect from you may be stored and processed in countries outside your country, including outside the European Economic Area (EEA), UK and Australia. 

For any transfers of data from the EEA or the UK, the data transfer will be under the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses; specifically, module one controller to controller transfer and or module two controller to processor transfer, as relevant for the UK Information Commissioner’s international data transfer addendum to the EU standard contractual clauses, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals’ rights and freedoms for their personal data (including transfers to the following countries: United States. Please contact us should you wish to examine a copy of these clauses.

We take appropriate measures to ensure that third-party recipients of your personal information outside of Australia manage it in accordance with Australian privacy laws. However, you acknowledge that we do not have control over, nor do we accept responsibility for, the actions and omissions of these third-party recipients. 

9. YOUR RIGHTS

Depending on where you live, you may have additional certain rights in relation to your personal information. Please refer to the applicable laws in your jurisdiction for more information on the rights applicable to you and how they can be exercised.

Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law:

• Access / Know: You may have the right to request access to the personal information we hold about you, and to obtain information about how we use it, and with whom we share or have shared it in the past.

• Deletion / Erasure: You may have the right to request that we delete personal information we hold about you. 

• Correction: You may have the right to correct inaccurate personal information we hold about you. 

• Portability: You may have the right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party. 

• Restriction of Processing: You may have the right to require us to stop, suspend or restrict our processing of personal information we hold about you.

• Objection: You may have the right to object to our processing of your personal information.

• Opt-Out of Marketing: You may opt out of marketing at any time by using the unsubscribe / opt-out function displayed in our communications to you. Please note that if you opt out, we may still send you transactional or administrative messages, such as emails about your account.

• Automated Decision-making: You may have the right to request human review of, express your views on or contest the outcomes of automated decision-making.

• Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent at any time.

• Complaint to a Regulator: You may also have the right to complain to your local data protection authority about how we process your personal data. Of course, we hope you will contact us first at the address below so we can resolve any issues.

You may also change or terminate your account at any time, and opt out from receiving push notifications regarding your account or certain features of the application(s) by  turning them off in your devices settings. 

California residents under the age of 18 who have registered to use the Services and have posted content or information on the Services can request that such information be removed from the Services. Such request must state that the California resident personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post or content from prospective public view or anonymize it so the minor cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished the post, and archived copies of it may be stored by search engines and others that we do not control.

If you live in France, you have the right to give us general or specific instructions regarding the retention, deletion, and sharing of your personal data following your death. Specific instructions apply only to the processing activities specified within them and require your explicit consent for execution. You can modify or withdraw your instructions at any time. You may appoint someone to oversee the execution of your instructions. This individual will be notified of your instructions upon your death and has the authority to request their execution from us. If no one is appointed, or if the appointed person is deceased, your heirs will have the right to be informed of your instructions and to request their execution from us.

If you live in Australia, when feasible, we will offer you the option to remain anonymous or use a pseudonym when registering an account or using the Services. You acknowledge that if you choose not to provide your personal information, we may be unable to grant you access to certain features or sections of the Services.

To exercise these rights, you can contact us or by referring to the contact details at the bottom of this Privacy Notice. 

10. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Notice, please email us at support@involio.com or contact us via mail at:

Involio, Inc.

8767 E Via de Ventura 

Scottsdale, AZ 85258 

United States.